14 March 2019

Managing Directors Train operating companies

BY EMAIL

Dear Colleague

Passenger Information - Compliance with condition 4 of GB Statement of National Regulatory Provisions: Passenger

Today we have published the findings and decisions relating to our investigations into Govia Thameslink Railway (GTR) and Northern Trains’ compliance with their obligations under Condition 4 of GB Statement of National Regulatory Provisions: Passenger (Information to Passengers). The purpose of this letter is to ask that you:

1. Provide written assurance that any service recovery framework and crisis management plan currently in place take adequate account of the key principles set out in this letter; and

2. Provide a copy of your arrangements and relevant contingency plans to support passengers that require additional assistance to travel during periods of disruption (both planned and unplanned).

Importance of passenger information

Rail passengers, like consumers in any other market, need access to good information about the products or services they intend to use or buy. In that context, our investigations demonstrate the importance of passenger information in operational decision-making, even during exceptional periods of disruption, and recognise that running a train service (or rail replacement bus) is only helpful to passengers if they know when and where the service will arrive, where it is going and how long the journey will take.

As you will be aware, Condition 4 requires train operators to provide appropriate, accurate and timely information to allow passengers to plan and make their journeys with a reasonable degree of assurance, including when there is disruption. Train operators must do so to the greatest extent reasonably practicable having regard to all relevant circumstances, including the funding available. Our guidance(^1) to support this licence condition recognises that the licence obligations are not intended to undermine the primary objective of providing the best available service for passengers. Making justified changes to the train plan to meet passengers’ needs should not be conditional on providing perfect advance information about these services. However, we would expect licence holders to use reasonable endeavours to get such information out as quickly and widely as possible.

We recognise the exceptional circumstances surrounding the May 2018 timetable change. However, the findings of our subsequent investigations show that train operators must be able to demonstrate that, even during periods of unprecedented disruption, they have to the greatest extent considered and put in place reasonable measures to ensure that:

- the provision of increasingly appropriate, accurate and timely information for passengers should be a core component of delivering effective service recovery following severe and prolonged disruption;
- there is clear senior level responsibility for ensuring that the provision of passenger information is sufficiently considered, developed and (where necessary) adapted as far as possible to align with and support the operational recovery process so that passengers can benefit from the service improvements being made;
- feedback from passengers and staff regarding information failures is actively reviewed and used to inform ongoing improvement in information provision;
- clear, and to the greatest extent reasonably practicable, accurate communication regarding the cause(s) of disruption, the known or likely impact on passengers, and the steps being taken to recover the situation is provided; and
- they undertake a proactive review of the lessons learnt after such events to continuously improve how passenger information is managed and used.

Please provide written assurance that any service recovery framework and crisis management plans currently in place take adequate account of the key principles set out above.

**Provision of information to support passengers that require additional assistance**

The impact of disruption on passengers that require additional assistance to travel, including those who rely on booked or unbooked assistance, can be particularly severe. In our response to the Transport Select Committee report(^2) into the May timetable change we referred to our recently published consultation on changes to the Disabled People’s Protection Policy (DPPP) Guidance, which offers an opportunity to reassess contingency planning for assistance provision during disruption. We proposed a requirement for operators to set out how they will contact passengers to inform them and discuss

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(^1) [http://orr.gov.uk/\_\_data/assets/pdf_file/0015/4353/information-for-passengers-guidance-on-meeting-the-licence-condition.pdf](http://orr.gov.uk/__data/assets/pdf_file/0015/4353/information-for-passengers-guidance-on-meeting-the-licence-condition.pdf)

(^2) [https://publications.parliament.uk/pa/cm201719/cmselect/cmtrans/1163/1163.pdf](https://publications.parliament.uk/pa/cm201719/cmselect/cmtrans/1163/1163.pdf) alternative arrangements where assistance booked in advance can no longer be provided because of service disruption.

Please provide a copy of your arrangements and relevant contingency plans to support passengers that require additional assistance to travel during periods of disruption (both planned and unplanned). We will ensure that good practice in this area is included in both our final DPPP Guidance and in revisions to the guidance on meeting licence condition 4 (Information to Passengers) to reflect the findings of these investigations.

Next steps

I would welcome any additional comments on lessons learnt from your experience of the May timetable change in the areas of passenger information and assistance provision, whether assistance has been booked or not.

As you may be aware, we are currently working with Network Rail and a number of operators to look at the wider area of passenger information to understand what might stimulate measurable and sustained improvement in the quality and consistency of information provided to passengers. We are grateful for the positive engagement in this work to date. We will report on the outcome of this research later this year and discuss with you the emerging areas for improvement to the passenger experience.

I would be grateful for your response to this letter by 5 April 2019. Please send your response to the following email address: passengerinformation@orr.gov.uk.

Please note that this letter and your reply will be published on our website.

Yours sincerely,

John Larkinson